There are lots of good articles out there on capitalisation including this one by my friend and professional colleague Julian Maynard-Smith.
Why make room for another in the packed internet content stall?
The answer is that, of all the style conundrums, whether or not to capitalise is one of the trickiest and most intractable, especially in the grey areas.
And one that is evolving rapidly. Internet anyone? Only a short while ago capital ‘I’ was the norm: no longer.
So I have no shame adding the Prism-Clarity view to the capitalisation fray. There are so many idiosyncrasies that it might be empowering to know that we can in some circumstances even if others don’t or we feel we shouldn’t.
I will follow the approach I have used for other style conundrums: Always Never Sometimes.
The Fundamental Review of the Trading Book (FRTB) is still a long way away – January 2022 at the latest estimate. But the time will pass quickly. Banks with trading activities need to be planning towards it now or soon.
This blog is derived from a piece of work I did recently for a potential client. It suggests an approach to defining a Target Operating Model (TOM) for implementing the FRTB.
In truth this will be mainly of interest to banks which have not yet started their FRTB planning. For example subsidiaries, smaller banks, and banks with marginal trading activities but exceeding the de minimis exemptions.
Most large banks are well under way with FRTB implementation, and have been for some time, participating in industry groups, Basel Quantitative Impact Studies (QIS) and routine monitoring, getting buy-in from their business leaders, corporate program leaders and strategic IT planners.
But smaller banks, in my experience, are not. Understandably, they prefer to wait and see. There are no real advantages to being first movers in this initiative, which has already evolved far – though not beyond recognition – since 2012.
With so many uncertainties along the path, including Brexit and the strategic regulatory and policy intentions of the US Administration, being in mid-pack is a smart play.
Still, it is worth having a long-term think ahead about how you might eventually implement these rules if you haven’t already.
*** Note: This blog does not constitute advice, but please contact Prism-Clarity for further information, including where to get the best advice. ***
This is the latest round-up in the series covering key announcements and developments in UK financial risk and regulation. I take my usual summarised and simplified approach to the main stories, but as always the regulators have been very busy.
A significant development for some of my clients and readers was the announcement by the Basel Committee of key changes to the Fundamental Review of the Trading Book (FRTB), the proposed revamp of the rules on market risk capitalisation of the trading book, which have been in development and consultation for some years: now due for implementation in 2022. See section 1.
Elsewhere, Fintech planning loomed large in the minds of regulatory and government agencies, especially but not only the European supervisory bodies. In similar vein but more broadly, Bank of England Governor Mark Carney made a thoughtful speech on the future of money in the light of the crypto-currency revolution. See section 2.
The topics mentioned here are just key highlights – see the detailed sections for more stories. See individual articles in this blog for links to underlying source stories or documents.
*** Note: The articles in this blog do not constitute advice, but please contact Prism-Clarity for further information, including where to get the best advice. ***
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